U.S. Opens Comments on China’s Shipbuilding Dominance Section 301 Action
Trade Update • June 9, 2025
he Office of the United States Trade Representative (USTR) announced a public comment process to consider proposed modifications to certain aspects of Annexes III and IV in the action (90 Fed. Reg. 17114, April 23, 2025) in the Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance.
Comment period opened on June 6, 2025, and the deadline for submission is July 7, 2025.
Section 301 Maritime Investigation
The investigation was initiated by USTR on April 17, 2024 (89 FR 29424), and culminated in a public report issued on January 16, 2025. The report detailed how, for nearly 30 years, China has systematically targeted the maritime, logistics, and shipbuilding industries through aggressive state-led strategies. These actions have diminished U.S. competitiveness, undermined supply chain resilience, and raised national security concerns.
On April 9, 2025, Executive Order 14269 was issued, directing a comprehensive government response. This includes new trade restrictions, a Maritime Action Plan, and proposed incentives for allied investment in U.S. shipbuilding. The formal determination by USTR on April 17, 2025 (90 FR 17114), established two implementation phases of the action, with service fees and restrictions imposed on specific maritime transport services.
Summary of Proposed Modifications
USTR is proposing adjustments under Section 307 of the Trade Act of 1974, which allows modifications to previously implemented Section 301 actions if they are no longer appropriate or feasible.
Annex III – Vehicle Carrier Fees
Fee Calculation Change: USTR proposes to change the basis of the fee from Car Equivalent Units (CEUs) to net tonnage, to enhance administrability and reduce evasion risks.
Targeted Exemptions: Vessels participating in the Maritime Security Program (MSP) would be exempt from fees. Additionally, vessels owned or operated by the U.S. government and vessels transporting U.S. government cargo would also be excluded.
Fee Structure:
Effective April 17, 2025: $0 per net ton (initial grace period).
Effective October 14, 2025: $14 per net ton (replacing the previously proposed $150 per CEU).
Annex IV – LNG Export License Suspension and Reporting
Elimination of Paragraph (j): USTR proposes to remove the authority to suspend LNG export licenses under paragraph (j), retroactive to April 17, 2025. This move addresses industry concerns about regulatory uncertainty and its chilling effect on the U.S. LNG sector.
Modification of Paragraph (k):
USTR seeks input on expanding LNG data reporting obligations to include vessel owners or operators, instead of terminal operators alone.
Public comment is also requested on whether restrictions under Annex IV should apply to owners or operators of vessels transporting LNG.
Summary of Proposed Modifications
Written comments must be submitted via the USTR electronic docket portal at:
🔗 https://comments.ustr.gov/s/
Use docket number USTR-2025-0013 and select the topic titled:
“Request for Comments Concerning Proposed Modification of Action Pursuant to the Section 301 Investigation of China’s Targeting of the Maritime, Logistics, and Shipbuilding Sectors for Dominance.”
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